January 10, 2012
All credit unions (yes, even Oregon credit unions) who do real estate lending in Washington State should be preparing their certifications to avoid a $250 fee and mandatory mediation on troubled real estate loans in 2012. Certifications are due to Washington’s Department of Commerce (DOC) by Jan. 31, 2012, and must be signed originals. There are two separate certifications needed, but the DOC has agreed to accept a single joint certification if the credit union qualifies.
To avoid the $250 fee on all notices of default issued in 2012, credit unions will need to certify that they issued fewer than 250 notices of default on owner-occupied residential real estate located in Washington State in 2011. The exception from the mandatory mediation requirement requires a certification that your credit union was not a beneficiary of deeds of trust on owner-occupied residential real estate located in Washington State in more than 250 trustee sales in 2011. Both of these certifications can be completed separately (if your credit union can avoid mediation, but not fees, for example) or jointly.
The DOC has provided templates for credit unions to use which have been uploaded to the resources section of Infosight.
Questions? Contact the Compliance Hotline: 1.800.546.4465, firstname.lastname@example.org.